Madarang v. Santamaria
REITERATIONFacts
1. The Antecedents: The underlying dispute involved L. J. Madarang and others seeking to prevent Francisco Santamaria, the judge of the Court of First Instance of Ilocos Sur, and Dionisio Abaya, et al., from disturbing their rights and properties. The petitioners sought damages in the amount of P40,000. 2. Procedural History: This case originated as an original action filed directly in the Supreme Court. Initially miscaptioned as an action by the United States against the Court of First Instance, it was clarified to be a civil action by Madarang and others against the Judge and other respondents. 3. The Petition: The petitioners sought a writ of preliminary injunction and, subsequently, a perpetual injunction from the Supreme Court. They also prayed for damages and costs. However, the Supreme Court denied the petition, citing its lack of original jurisdiction to issue injunctions as a standalone remedy, as provided by Section 17 of Act No. 136, which limits original jurisdiction to writs of mandamus, certiorari, prohibition, habeas corpus, and quo warranto.
Issue(s)
Whether the Supreme Court has original jurisdiction to issue a writ of injunction. Whether a preliminary injunction can be granted by the Supreme Court in an original action not connected with another remedy or pending case.
Ruling
The petition is denied. The Supreme Court does not possess original jurisdiction to grant a writ of injunction, except when it is ancillary to another remedy or in an action already pending before it.
Ratio Decidendi
On the issue of the Supreme Court's original jurisdiction to issue a writ of injunction: The Court held that, in accordance with section 17 of Act No. 136, the Supreme Court's original jurisdiction is limited to issuing writs of mandamus, certiorari, prohibition, habeas corpus, and quo warranto. The said section makes no provision for the granting of a writ of injunction as an original action in the Supreme Court. Therefore, the Supreme Court cannot entertain an original action solely for the purpose of issuing an injunction. On the issue of granting a preliminary injunction in an original action: The Court reiterated its previous rulings that an application for a preliminary injunction will be denied by the Supreme Court unless the same is petitioned for in connection with some other remedy or in an action actually pending in that court. This means that the Supreme Court's power to issue injunctions is generally exercised in aid of its appellate jurisdiction or in cases where it has original jurisdiction over the main action. The present case, being an original action solely for an injunction, does not fall within these exceptions. The petitioners' prayer for damages does not transform the nature of the action into one where the Supreme Court has original jurisdiction to grant an injunction as a principal remedy.
Main Doctrine
The Supreme Court does not have original jurisdiction to grant a writ of injunction unless it is petitioned in connection with some other remedy or in an action actually pending before the court.